Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 1988-286 (not yet in the library — opens the official source)
69 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  2. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003★ strong match
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
  3. 103 T.C. 200; 103 T.C. No. 13 — Rubin v. Commissioner
    IRCCourt RulingsAug 15, 1994
    …oration timely filed its Federal income tax return, Form 1120S, for its taxable year ended June 30, 1988, on September 15, 1988. The corporation made the following timely contributions to the trust forming a part of the Resource Systems, Inc. Employees Pension Plan (the plan) for the plan’s year ended June 30, 1988: On…
  4. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995★ strong match
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
  5. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997
    x 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661(a) 1987 $7,348-367 1 - 1988 29,345 2,935 1,467-7,336 1 50 percent of the interest due on the deficiency. Unless otherwise indicated, all section and Code references are to the Internal Revenue Code as in effect for the years in issue, and all Rule references are to the Tax …
  6. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …Loan No. 1310001. Ex. C23. 10CD No. 11813-17572 was outstanding from October 13, 1987 to January 1, 1988 at an annual interest rate of 7.00%. Ex. C10. 11CD No. 11813-17579 was outstanding from October 19, 1987 to January 1, 1988 at an annual interest rate of 7.00%. Ex. C26. 12CD No. 11813-17578 was outstanding from Oct…
  7. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
  8. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996★ strong match
    …red from the Accumulation Fund to the Annuity Savings Fund. Md. Ann. Code, art. 73B, sec. 14(2)(c) (1988). Benefits, are paid from the Expense Fund. Md. Ann. Code, art. 73B, sec. 14(3) (1988 and Supp. 1991). The Annuity Savings Fund holds a participant's "accumulated contributions", which consist of the participant's t…
  9. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
  10. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    …reply brief includes 4-½ pages of objections to respondent's proposed findings of fact. Id . I. The Memorandum Opinion In T.C. Memo. 1995-492, filed October 11, 1995, the Court decided the present case. In our memorandum opinion, we rejected petitioners' argument that petitioner's Transfer Refund had not been received …
  11. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
    IRCCourt RulingsFeb 12, 2003★ strong match
    d caselaw require that corrective actions must be taken to requalify a plan that has violated section 415. Martin Fireproofing v. Commissioner , supra at 1184; sec. 1.415-6(b)(6), Income Tax Regs. Petitioners provided calculations to establish that the plan was qualified as of the taxable year ending June 30, 1987. In …
  12. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997
    as in fact only $7,992,215. The deductible contribution amount for the 1988 plan year was $13,243,405. 5 During the 1988 year, $4,092,000 was paid for PRMB's. Accordingly, the increase in the required reserve at the 1988 plan yearend is $9,151,405 ($13,243,405 less $4,092,000). Consequently, the total reserve balance s…
  13. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    IRCCourt RulingsSep 3, 1998★ strong match
    …his Court under substantially identical circumstances. See Steel Balls, Inc. v. Commissioner , T.C. Memo. 1995-266, affd. without published opinion 89 F.3d 841 (8th Cir. 1996). 6 We rejected the same argument presented herein and concluded that respondent's position was clearly supported by the statute and regulations.…
  14. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
  15. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …5 06/01/1987 07/01/1987 7.50 07/01/1987 10/01/1987 7.75 10/01/1987 11/01/1987 8.00 11/01/1987 03/01/1988 8.25 03/01/1988 04/01/1988 8.00 04/01/1988 06/01/1988 7.75 06/01/1988 09/01/1988 8.00 09/01/1988 11/01/1988 8.25 11/01/1988 04/01/1989 7.75 04/01/1989 06/01/1989 8.00 06/01/1989 08/01/1989 7.75 08/01/1989 09/01/1989…
  16. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …819-91 MIT 82 1986 $428,142 14820-91 MIT 83 1986 519,960 3453-92 MIT 85 1986 412,722 1987 1,865,187 1988 1,419,986 3456-92 MIT 82 1987 840,069 1988 275,156 1989 1,274,633 3457-92 MIT 80 1986 443,415 - 7 - 1987 840,838 1988 969,316 1989 1,335,995 3461-92 MIT 84 1986 546,300 1987 1,315,352 1988 23,889 1989 1,423,786 3462…
  17. Treas. Reg. § 1.410(b)-7(c)(4)(i)(D) — Definition of plan and rules governing plan disaggregation and aggregation.
    IRCRegulationsSep 9, 2016
    ce 1989 and worked for Division M from 1981 to 1988. Employee C has worked in the headquarters of Employer X since 1981. For the period 1981 to 1988 Employee C was credited with years of service under Plan P. (b) For purposes of the benefits accrued by Employee A under Plan P during years 1981 through 1997, Employee A …
  18. Treas. Reg. § 1.412(c)(2)-1(b)(9) — Valuation of plan assets; reasonable actuarial valuation methods.
    IRCRegulationsSep 9, 2016
    …by averaging fair market value over 4 years. An actuarial valuation is performed as of December 31, 1988. (i) The average value as of December 31, 1988, is computed as follows: 1986 1986 1987 1987 1988 1988 Fair market value: Jan. 1 $150,000 $196,500 $238,000 Contributions $65,000 $62,000 $66,000 Benefit payments (22,0…
  19. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10066-93. Filed October 3, 1995. Harold L. Humberson, pro se. Alan R. Pere…
  20. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…